National Environment

Management Council (NEMC)

MANAGING COMPLIANCE AND
OPERATIONAL RISKS

MARCH 2016
Outline of Presenta/on:
What is Risk?
Risk Management?
Sustainability & Environmental Risk
Environmental challenges
Environmental assessment of opera=ons and
ac=vi=es
 What is Risk?
Risk is present in everything we do.

ISO 31000 deni=on of risk:

Risk = the eect of uncertainty on objec/ves.

Risk can be a threat or an opportunity

Anything that could harm, prevent, delay or enhance
your ability to achieve your objec=ves = risk
 Enterprise Risk Management (ERM)?
Risk Management is a coordinated eort to
direct and control all ac=vi=es related to risk.
Risk is the eect of uncertainty on objec/ves. It
therefore =es the management of risk to what is
most important to the organiza=on.
The responsibility for managing risk is spread
across the organiza=on to those who have
accountability and authority risk owners.

 Types or Risk Exposures in ERM
} Hazard risk
risks related to accidental losses, such as workplace injuries, property
damage, and natural disasters.
} Financial risk
risks related to nancial ac=vi=es, such as pricing, asset valua=on,
currency uctua=ons, and liquidity.
} Opera/onal risk
risks related to opera=ons, such as supply chain, customer
sa=sfac=on, product failure, or loss of key personnel.
} Strategic risk
risks related with an organiza=ons long-term goals and management,
such as partnerships, mergers, and acquisi=ons.
} Compliance risk
risks related to viola=ons of or nonconformance with laws, rules,
regula=ons, prescribed prac=ces, internal policies, and procedures, or
ethical standards.
} Reputa/onal risk
risks related to the trustworthiness of business. Damage to a rm's
reputa=on can result in lost revenue or destruc=on of shareholder
value.

What is Sustainability?
What is Environmental Risk?

Environmental risk - arises from the rela/onship

between humans and human ac/vity and the
environment

Ecological risk management - deals with risks

associated with past, present and future human
ac/vi/es on ora, fauna and ecosystems. It is a sub-
set of environmental risk management

Types of Environmental Risk:
Risk to the environment - this type of risk recognises that ac/vi/es of
an organisa/on can cause some form of environmental change
(Environmental risks can relate to ora & fauna; human health & wellbeing; human
social and cultural welfare; earth, air and water resources; energy and climate)

Risk to an organiza/on from environment-related issues - this
includes the risk of not complying with exis/ng (or future) legisla/on
(Associated risks include business losses an organiza=on may suer as a result of
poor management, such as loss of reputa=on, nes, costs of li=ga=on, and from
failure to secure & maintain permission for development and opera=onal ac=vi=es

Both have environmental, legal, nancial, reputa/onal and opera/onal impacts
Key Deni/ons (1):
Source of Risk all sources of a risk where there is a cause-eect
rela/onship
Hazard a source of poten/al harm
Environmental aspects elements of an organisa/ons ac/vi/es, products
or services that can interact with the environment
Incidents (aka Event) any occurrence that can have impact on the
environment (an incident releases the intrinsic poten/al of the hazard)
Impacts include, where relevant, eects and consequences
Consequence is the outcome of impact of an event
Environmental impact any change to the environment wholly or partly
resul/ng from an organisa/ons ac/vi/es, products ort services
Risk management structured, systema/c approach to decision-making
Key Deni/ons (2):
Need to manage environmental risk but how?
Environmental management system (EMS) - refers to the
management of an organisa/on's environmental programs in a comprehensive,
systema/c, planned and documented manner:
Serves as a tool to improve environmental performance
Provides a systema/c way of managing an organisa=ons
environmental aairs
Addresses immediate and long-term impacts of its products, services
and processes on the environment
Gives order and consistency for organisa=ons to address
environmental concerns through the alloca=on of resources,
assignment of responsibility and ongoing evalua=on of prac=ces,
procedures and processes
Focuses on con/nual improvement of the system
An EMS follows a Plan-Do-Check-Act Cycle
Process ow for the management of an
audit programme
Key Elements of an EMS:
Policy Statement - a statement of the organiza=ons
commitment to the environment
Iden=ca=on of Signicant Environmental Impacts -
environmental a^ributes of products, ac=vi=es and
services and their eects on the environment
Development of Objec/ves and Targets -
environmental goals for the organiza=on
Implementa/on - plans to meet objec=ves and
targets
Training - instruc=on to ensure employees are aware
and capable of fullling their environmental
responsibili=es
Management Review
 Environmental Risk Assessment
Aspect
Iden=ca=on UQ as an example
Established and mature system.
Hazard Evolved from a cer=ed ISO 14001 system.
Iden=ca=on
Recognises rela=onships with:
OH&S risk,
Risk
Assessment Legal risk, and
Financial risk.
Risk
Priori=sa=on
What is environmental management
and ISO 14001?

ISO 14001 is an interna=onally accepted standard
that outlines how to put an eec=ve
environmental management system in place in
your organiza=on.
It is designed to help businesses remain
commercially successful without overlooking
environmental responsibili=es and impacts. It can
also help you to grow sustainably while reducing
the environmental impact of this growth.
 Aspects
Aspect
Iden=ca=on
Purpose:
Complete understanding of impacts.
Hazard
Engage stakeholders.
Iden=ca=on Raise awareness.
Review exis=ng aspects.
Risk
Assessment

Risk
Priori=sa=on
 Aspects
Aspect
Iden=ca=on
Common: Unusual:
Oce and Transport.
administra=on. Sewage treatment.
Hazard
Iden=ca=on Teaching. Incinera=on.
Laboratories & Farming.
Risk Research. Mine opera=ons.
Assessment ITS.
Maintenance.
Risk
Priori=sa=on
 Environmental Hazards
Aspect
Iden=ca=on
Common: Unusual:
Chemicals. Nanopar=cles.
Hazard Dust. Radia=on.
Iden=ca=on Fire. GMOs.
Noise. Clinical agents.
Risk Light. Biological.
Assessment
Waste. Explosives.
Gases.
Risk
Priori=sa=on
 Environmental
Environmental
HRazards
isks
Aspect
Iden=ca=on
Common: Unusual:
Chemicals. Nanopar=cles.
Hazard Dust. Radia=on.
Iden=ca=on Fire. GMOs.
Noise. Clinical agents.
Risk Light. Biological.
Assessment
Waste. Explosives.
Gases.
Risk
Priori=sa=on
 Environmental Risks
Aspect
Iden=ca=on
Common: Unusual:
Legal. Climate change.
Hazard Pollu=on. Consump=on
Iden=ca=on Contamina=on. (i.e. non-renewable
Nuisance. resources).
Risk Inadvertent harm.
Assessment

Risk
Priori=sa=on
 Priori/sing
Aspect
Iden=ca=on
Common:
Priori=se by greatest risk.
Hazard
Iden=ca=on
Complexi/es:
Intrinsic risk can be high risk.
Risk
Assessment Compe=ng risks do not equal the
environmental risk.
Risk
Priori=sa=on
 Assessment Process
Aspect
Iden=ca=on
Stakeholders

Hazard
Iden=ca=on
Sustainability
Oce
Risk
Assessment

Management
Risk
Priori=sa=on
 as an Example
Chemicals: Iden/ca/on and Assessment.
Operation Activity/Aspect Risk Controls Legal
Bulk Flammable and Storing FCLs in rooms and Fire or spill causing contamination of receiving Must follow regulations Council bylaw.
Combustible Stores buildings. environment
Laboratories - daily Storing and using chemicals Spillage of chemical escaping to soil or receiving Must follow regulations OHS Regs
operations. within laboratories. waters

Fume cupboards Use of chemicals in fume Loss of volatile chemicals to atmosphere. Local procedures No
cupbords.
Fieldwork Use of chemicals in the field. Loss of chemicals to the receiving environment. Local procedures No

Transporting Materials - Transporting chemicals by Loss to the environment by spilling. Follow regulations DGSM Act.
Chemicals vehicle between or around
campuses and sites.

Transport Use of chemicals during Loss to the evironment through spills and improper Areas bunded. Disposal systems provided. ERA
maintenance. disposal.
Waste Management - Disposal of sewerable Release to the environment by improper or non- EMS EPP Waste
Chemical chemicals. sewerable chemical disposal.

Waste Management - Disposal of non-sewerable Improperly disposed and being released to the EMS. Contractor for collection and disposal. EPP Waste
Chemical chemicals. receiving environment.

Printery Use of volatile chemicals Release to the environment None ERA

and solvents
Disaster Management Fire in a chemical store or Chemicals volatilised and released to the atmosphere. Fire protection. Response processes. Stored in Council bylaw.
location accordance with code and Act
Disaster Management Fire in a chemical store or Chemicals washed to Brisbane river in fire water Fire protection. Response processes. Stored in Council bylaw.
location accordance with code and Act
Central Chemical Store - Decanting Chemicals Spillage of chemical escaping to soil or receiving Bunding. Drainage to sewer. Council bylaw.
Daily Operations waters
Chemical Waste Store - Storing waste chemicals. Loss of chemicls to the Brisbane river through spill or Bunded. Small containers. Frequently cleared. No
Daily operations leak.
Chemical Waste Store - Flood inundating the store. Loss of chemicals to the Brisbane River. Containers small. Volumes kept low. Can be No
Incident cleared with warning.
Cleaning - Daily Use of chemical cleaners Spills of chemicals to receiving environment. Cleaning rooms bunded and plumbed to sewer. No
operations
Disaster Management Release of fire water from Release of chemicals to receiving waters None No
site.
Workshop - chemical Storing chemicals in the Spills being released to the creek. Spill kit. No
storage workshop.
CAAS - Chemical Storage of bulk volumes of Leaks being lost to receiving environment. Bunded. Spill processes ERA
Treatment Facility NaOH
Chemical Waste Store - Fire Release to the Brisbane River in fire water. Containmanet tank. Volumes kept low by weekly No
Incident pick up.
Chemical Waste Store - Fire Release to atmosphere in smoke plume Volumes kept low by weekly pick up. No
Incident
Swimming Pool - Daily Use of chemicals in Contamination of surface waters in the event of a spill None EPP Water
Operations maintenance
Washing up with detergents Release of chemicals to sewer and receiving waters All such sinks are connected to sewer. Plants are No
tertiary treated.
Tea Rooms
Use of chemicals in Contact with incompatible materials. Spill kit. Training None
Swimming Pool - Daily maintenance
Operations
Traffic and Parking Deterioration of paint used Entering natural water bodies. None None
for line marking.
 as an Example
Chemicals: Iden/ca/on and Assessment.
Operation Activity/Aspect Risk Controls Legal
Bulk Flammable Storing FCLs in Fire or spill causing contamination of Must follow regulations. Council bylaw.
and Combustiblerooms and receiving environment
Stores buildings.
Laboratories - Storing and using Spillage of chemical escaping to soil Must follow regulations. OHS Regs
daily operations.
chemicals within or receiving waters
laboratories.
Fume cupboards Use of chemicals Loss of volatile chemicals to Local procedures. No
in fume cupboards. atmosphere.
Fieldwork Use of chemicals Loss of chemicals to the receiving Local procedures. No
in the field. environment.
Transporting Transporting Loss to the environment by spilling. Follow regulations. DGSM Act.
Materials - chemicals by
Chemicals vehicle between or
around campuses
and sites.
Waste Disposal of Release to the environment by EMS. EPP Waste
Management - sewerable improper or non-sewerable chemical
Chemical chemicals. disposal.
Waste Disposal of non- Improperly disposed and being EMS. Contractor for collection EPP Waste
Management - sewerable released to the receiving and disposal.
Chemical chemicals. environment.
Printery Use of volatile Release to the environment None. ERA
chemicals and
solvents
 as an Example
Chemicals: Risk Management.
 2009 Risk Assessment
Aspect
= 126 Aspects Environmental Aspects Against Risk
Iden=ca=on
200

#of Aspects
160

Hazard 120
= 72 Hazards
Iden=ca=on 80

40

0
Risk
= 290 Risks
Assessment
Risk

Risk = 34 Unacceptable Risks

Priori=sa=on = 10 Dierent Hazards
 2009 Risk Assessment
Aspect
Historic Environmental Risks
Iden=ca=on
100

75
Percentage (%)
Hazard
Iden=ca=on
50
"Acceptable"
"Unacceptable"
Risk 25
Assessment
0
2005 2006 2007 2008 2009
Year
Risk
Priori=sa=on
 Priori/sing
Aspect
Iden=ca=on
Common:
Priori=se by greatest risk.
Hazard
Iden=ca=on
Complexi/es:
Intrinsic risk can be high risk.
Risk
Assessment Compe=ng risks do not equal the
environmental risk.
Risk
Priori=sa=on
Project Scope:
Iden/fy the current and poten=al environmental issues and
liabili=es at University
Determine and assess the level of environmental risk
associated with ac=vi=es undertaken at the University
Ascertain the adequacy of control measures associated with
current and poten=al environmental issues and liabili=es
Conduct environmental legal compliance assessment in order
to evaluate compliance with environmental legal obliga=ons

Conduct a gap analysis against the Interna=onal ISO 14001
Standard in order to facilitate the development of an EMS
Iden/fy and recommend measures for improvement
Overview:
Methodology:
Iden=ca=on of Environmental Ac=vi=es &
Risk Assessment
Legal Compliance Assessment
ISO 14001 Gap Analysis
Results:
Iden=ca=on of Environmental Ac=vi=es &
Risk Assessment
Legal Compliance Assessment
ISO 14001 Gap Analysis
Recommenda/ons:
Methodology:
1.Iden/ca/on of Environmental Ac/vi/es & Risk
Assessment
(a)Hazard Iden/ca/on
Segrega=on of processes/ac=vi=es within each
Area
Inspec=on and observa=on of work areas
Interviews with sta
Iden=ca=on of the current and poten=al
environmental issues and risk (liability) and its
eect/impact on the environment under a range
of opera=ng condi=ons
Iden=ca=on of exis=ng control measures
Determina=on of proposed risk reduc=on/control
measures
Methodology:
(b) Risk Assessment
Workshops and par=cipant risk ranking sessions
Determina=on of inherent and residual risk
Determina=on of consequence, likelihood and risk ra=ng
Any risks classed as High, Very High or Extreme were
recognised as being signicant

(c) Risk Control

Iden=ca=on of proposed or addi=onal control measures
Methodology:
2. Assessment of Legal Compliance
Review of ERAs, no=able ac=vi=es, documents, records
and per=nent legisla=on and other requirements
Inspec=on and observa=on of work areas
Findings were coded as follows:
Non-compliance (NC) A direct non-compliance with a
Statutory requirement. Typically of a higher risk or
consequence
Observa/on (O) - Provided as guidance or comment to
facilitate improvement in performance. Should be ac/oned
where prac/cable
Methodology:
3. ISO 14001 Gap Analysis
Iden=es the ac=ons needed to qualify for ISO 14001
cer=ca=on
Assessment against each element of ISO 14001 Standard:
Policy
Emergency preparedness and response
Responsibili=es and accountabili=es
Environmental monitoring
Records and data management
Incident repor=ng
Planning and implementa=on of ini=a=ves &
programs
Compliance Score (%) determined
Results Impact by Category:
Results compliance risks:
Overall, an understanding of statutory obligations relative to
environmental management and performance is demonstrated
The assessment identified 25 instances of non-compliance
with environmental legislation. These related to:

Conduct of a notifiable activity without approval (1)

Management & storage of hazardous substances &
dangerous goods (18)
The establishment & maintenance of documentation (6)

All 25 non-compliances will be addressed by end of Nov 2010

Results Gap Analysis:
70% compliance with Communica=on, Emergency
Preparedness & Response, Control of Records and Roles,
Responsibili=es and Authority
50% compliance with Environmental Aspects, Legal &
Other Requirements, Objec=ves & Targets, EMS
Documenta=on, Monitoring & Measurement, Evalua=on
of Compliance and Preventa=ve and Correc=ve Ac=on
<40% compliance with Competency, Training &
Awareness, Document Control, Opera=onal Control and
Internal Audit
0% compliance with Environmental Policy and
Management Review
Recommenda/ons:
Develop an Environmental Management Plan
(EMP)
Conduct of environmental audits of contractors
used for the collec=on & transport of general &
regulated waste
Provision of formal hydrocarbon and chemical
spill response training
Development of wide chemical spill response
procedure and incident repor/ng procedure
Installa=on of general and chemical spill kits
Regular inspec/ons of ammable storage
cabinets
Development of standard templates
Laboratories: SOPs for eldwork
Recommenda/ons (Cont.):
Increase level of educa/on and
awareness:
Waste management
Separa=on of hazardous substances
Environmental incident repor=ng
Environmental risk assessment
Signicant environmental impacts
(risks)
Emergency response procedures
Legal obliga=ons and statutory
guidelines
Address non-compliances raised in the
legal compliance assessment
Encourage eco-friendly packaging and
increase recycling eorts
 THANK YOU

FOR YOUR ATTENTION